The FCC has now suspended the old Forms 323 and 323-E ownership reports that were filed in the Consolidated Database System (CDBS), and unveiled a new report that must be filed in the License Management System (LMS). At a webinar on November 28, 2017, the FCC detailed the new form and procedures for completing and getting it filed. There are more than a few interesting wrinkles there, which makes us thankful that the FCC previously announced a three-month extension of the normal December 1st deadline for all broadcast stations to file their 2017 Biennial Ownership Reports. Reports that would have been due by December 1, 2017 are now due no later than March 2, 2018. The now-one-year old suspension of ownership reporting for noncommercial stations was also extended through March 2, 2018. Don’t forget that the information to be reported in these filings must be accurate as of October 1, 2017. As we recently learned, even stations that are sold after this date are still required to file the form by the deadline because they owned the station on October 1, 2017.

Now for the wrinkles. Wrinkle No. 1. To add people or entities to the form that are attributable for reporting purposes, you can only do so by entering an FRN. You can’t just type in a name. The form then auto-populates with the entity or individual’s name. You then enter address information. So, in other words, the software is FRN designed to coincide with the “everyone must have an FRN” requirement to facilitate the FCC’s ownership tracking efforts. Wrinkle No. 2. None of the data from previously filed ownership reports in CDBS migrates over to the form in LMS. So that means starting from scratch.

We’re just getting started, so there are more wrinkles to be discovered. Sigh. We get that this is the FCC’s latest way to collect ownership data efficiently. But the new form and filing system are an uphill climb for broadcasters, and at this point, the hill is pretty steep.